Arbitrary valuation cannot stand when unsupported by reasons; accepted plantation value remained undisturbed in principle.

A Tribunal valuation of a teak wood plantation was set aside where it reduced the accepted figure without cogent reasons or supporting material. The approved valuer's report had been accepted by the accountable person and was not shown to be illegal or infirm, so the Tribunal could not reject it on surmise or on an unsupported assumption of impending legislation. Although market valuation is ordinarily a question of fact, an arbitrary estimate made without principle is not binding. The valuation accepted by the Appellate Controller was therefore left undisturbed in principle, and consequential orders were to follow on that limited aspect.

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Issues: Whether the Tribunal was justified in reducing the value of the teak wood plantation by about 85% despite the valuation accepted by the Appellate Controller.

Analysis: The approved valuer's report was accepted by the accountable person and was not shown to be illegal or infirm. The Tribunal did not give any cogent basis for rejecting that valuation and fixing a higher figure of Rs. 16 lakhs, nor for further reducing that figure to 15% on the basis of impending legislation. The valuation adopted by the Tribunal was unsupported by material and rested on surmise and ipse dixit. While market valuation is ordinarily a question of fact, a finding reached arbitrarily and without principle is not binding.

Conclusion: The Tribunal was not justified in reducing the value of the teak wood plantation; the question was answered in the affirmative, against the assessee and in favour of the Revenue.

Final Conclusion: The valuation accepted by the Appellate Controller stood undisturbed in principle, and the Tribunal was directed to restore the appeal and pass consequential orders in accordance with law on the limited aspect.

Ratio Decidendi: A valuation finding unsupported by cogent reasons or legal principle, and resting on arbitrary estimation, is not binding despite being framed as a question of fact.

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